Thursday, February 15, 2007
Most Important Decision Since 2002
No other decision the Oconee County Board of Commissioners has made since it decided to begin offering residential sewage service in late 2002 is likely to be as important as the decision the Board will be considering on Tuesday, February 20.
At that meeting, the Board, it now appears, will be asked to join Walton County in a reservoir project on Hard Labor Creek that will cost more than $100 million in 2007 dollars.
The 2002 decision on sewers has led to the hyperdevelopment now taking place in the County, with the 900-home Parkside master plan development project now coming online a prime example. Parkside, which lies between Mars Hill and Hog Mountain roads, will funnel even more traffic onto those already stressed thoroughfares and send more students to overcrowded schools.
A decision to spend more than $100 million on a reservoir will spur more development, probably along U.S. 441, since the corridor between Hog Mountain Road and SR 316 now is nearly built out. This new development, in turn, will further stress County resources, such as the schools, the sheriff’s office and the volunteer fire service.
Huge infrastructure projects such as the planned sewage plant on Rocky Branch Road and the reservoir are billed as a response to development, but they are actually the cause of it. In order to pay for the sewers, the County passed a master plan development ordinance to encourage high-density development.
I remember a conversation I had with Wayne Provost, then head of planning in the County and now director of strategic and long-range planning, when the MPD was being discussed. "Not everyone wants a house with a three-quarter acre lot," he said. The County needed to allow higher density projects in order to continue to develop, the argument went.
The sewers were to spur development, not respond to it.
In order to pay for the water reservoir to be discussed on Tuesday night, the County will have to run water to parts of the County not presently served, such as to the south along U.S. 441. The water lines will be to encourage future development, since only with such development will the County be able to pay for the reservoir.
County officials don’t like to talk about infrastructure development in this way. They always say development is inevitable and they must respond to it. My guess is they know most people are not in favor of the break-neck pace of development they have brought to the County.
Elected officials also know that few voters like tax increases, which infrastructure projects usually require.
At the January 17 meeting held to discuss water options, no one could–or would--answer questions about how the projects would be financed. In an article in the February 15 edition of The Oconee Leader, Board Chairman Melvin Davis offered only options, including the spending of special interest tax revenues, rather than a specific plan.
A glance around the County gives a sense of how quickly tax revenues are being spent. We have a new jail under construction. A new recreational facility is in the works. If the County gets its permit to begin dumping treated sewage water into Barber Creek, it will begin construction of a new sewage plant.
The February 15 issue of the Athens Banner-Herald indicates that the County may be asking for tax increases in the future to spend on much needed road improvements.
To lessen the burden on those of us already living here, County officials will encourage construction of even more residential units, even though residential development does not produce tax revenue sufficient to offset its demand for services.
The cycle will then continue. The increase in water coming into the County will bring about the need for larger sewage plants and more roads and more schools and more jails and a larger courthouse and bigger roads. And more sewage water being dumped into such streams as Barber Creek.
The irony is that most of us moved to Oconee County in the hopes that some of the rural character and quality of life that brought us here would be retained.
Melvin Davis, who is both the chief County executive and chairman of the legislative body, the Board of Commissioners, is the one pushing for a decision now on the reservoir project. In fact, he has been the chief advocate for most of the development projects in the County. The article in The Leader makes it clear he wants the Board of Commissioners to join the Hard Labor Creek reservoir project in Walton County.
Wouldn’t it be nice if the four members of the Commission told him it was time to slow down, consider all the options, examine some of the smaller reservoir projects on the table, and give some serious thought to water conservation?
I urge you to write to the Commissioners immediately and encourage them to show some independence. One option would be for them to appoint a citizen group to review the different reservoir plans. The County at present is relying on the advice of consultants who stand to gain most from big projects.
Here is the contact information for the Commissioners:
Jim Luke, jluke@oconee.ga.us
Don Norris, dnorris@oconee.ga.us
Margaret Hale, mshale@oconee.ga.us
Chuck Horton, chorton@oconee.ga.us.
If at all possible, attend the meeting on the 20th and tell the Commissioners how you feel about the pace of development in the County and the need for a go-slow approach to such a mammoth project. Bring a neighbor or two if you can. The meeting starts at 7 p.m.
Tuesday, January 30, 2007
Psst! Wanna buy some sewage water?
It’s not fit to drink or touch, but it is cheap!
Oconee County plans to charge customers who use treated sewage water from its Rocky Branch waste treatment plant, rather than give the water away, officials said at the January 17 meeting called to discuss the County’s plans for water reservoirs.
The County will maintain separate meters for use of the treated sewage water and plans to recover some of the costs of pumping the water to customers through a usage fee.
Wayne Provost, the director of strategic and long-range planning for the County, made the announcement about fees for use of the sewage water in response to a question at the meeting. Utility Director Gary Dodd elaborated.
"There will be a minimal charge for the reuse water because it is being pumped, it is being piped, it is being metered to those homes or facilities that are using it, so there has to be a charge," Mr. Dodd said.
The County did not mention plans to charge for use of the sewage plant effluent at either the March 14, 2006, or December 12, 2006, public hearings on the proposed upgrade of the Rocky Branch Plant.
Developers are running separate water lines, one for drinking water and the other for treated sewage water, in some subdivisions, such as the mammoth Parkside with its nearly 900 home sites. The reuse water is to be used for fertilizing lawns.
The County ordinance, passed in March of 2005, stipulates that reuse water should NOT be used for the following: "drinking, food preparation, hand washing, automobile washing, or irrigation of fruits and vegetables."
EPD regulations specifically recommends against any use that brings the treated water into contact with the skin and prohibits the use of the water for consumption by humans or animals, sprinkling of edible crops, body contact recreation, or filling of swimming pools.
At the December 12 hearing, an EPD officer said the EPD recommended anyone who touches the reuse water wash his or her hands before touching anything else.
At the January 17 discussion of reservoirs, the County touted the scheme to distribute reuse quality water as a cost-saver. Rather than treat the water from the sewage plants to drinking level quality, which is technologically possible, the County will save money by treating it to a lesser standard.
By using the treated sewage water, rather than drinking water, for watering lawns, the customers will save both themselves and the County money.
It is an open question whether people living in the subdivisions will choose to use the treated sewage water rather than drinking water, even if it saves them some money. It is common for children and pets to play in sprinklers and for customers to water both their vegetable gardens and fruit trees when they water their lawns.
Privately, County officials have recognized that a reuse market for the water may not develop quickly. In an email message Mr. Dodd wrote to Jim Sunta of Precision Planning on December 20, 2005, he said "I agree with your assumption that the reuse customer base will be slow to develop."
If the reuse market doesn’t materialize, the effluent of Rocky Branch sewage plant will be dumped into Barber Creek, if the County is given a permit to do that by the state Environmental Protection Division. That permit is pending.
The County also has not openly discussed other costs associated with the plan to develop the reuse market. While some developers are being encouraged to build the dual distribution system, when the developers complete their subdivisions, they will turn over the infrastructure, including the two water distribution systems, to the County for future maintenance.
The cost of maintaining dual distribution and metering systems has not been discussed at the two public hearings.
The promotion of use of the treated sewage water for irrigation also is at odds with current EPD plans to encourage water users to return as much water as possible to the streams from which the water has been taken.
The Bear Creek Reservoir, from which Oconee County is currently drawing most of its water, draws that water from the Middle Oconee River. Barber Creek flows to McNutt Creek and then back to the Middle Oconee.
Petitions signed by Friends of Barber Creek asked the EPD to require the County to treat any water it returned to Barber Creek to drinking water quality and to restrict the release to periods of normal water flow. In addition, we asked the EPD to do independent monitoring.
Jordan Jones and Goulding, the consulting firm the County hired to develop a wastewater treatment plans for the County, actually recommended that the County phase out its two existing waste water treatment plants–on Calls Creek and on Rocky Branch Road–and build a new plant on the Middle Oconee.
The January 17 meeting was about water, but, County officials acknowledged, at least implicitly, the linkage between the waste water treatment and drinking water treatment.
The amount of water the County brings in for drinking water increases the amount of water the County will have to treat at its sewage plants.
Both waste water treatment and drinking water treatment are functions of the County’s Utility Department. The debt the County takes on for water treatment and sewage treatment will have to be retired by that department and will be the responsibility of the County overall.
Both treatment of water for drinking and treatment of sewage water for discharge is done by plants using the same basic membrane filtrate technology.
It is quite possible to treat sewage water to drinking level quality. It is being done at a sewage plant in operation in Gwinnett County. And it is done many places around the world, as Jimmy Parker, from Precision Planning, acknowledged at the January 17 meeting.
So why won’t we do that in Oconee County?
"We don’t mind drinking other people’s waste water," Mr. Parker said in response to my question on this topic. "We just don’t want to drink our own."
One of the two reservoirs proposed would be downstream from an Athens sewage treatment plant. The other would be downstream from Monroe’s sewage treatment plant.
In fact, if the County gets its way and is given permits to discharge treated sewage from the Rocky Branch Waste Treatment plant into both Barber Creek and the Apalachee River, both proposed reservoirs would be downstream from Oconee sewage treatment plants.
So we may not like drinking our own waste water, but that is exactly what the County is proposing. It just doesn’t want to talk much about it.
Thursday, January 25, 2007
Water Council Meeting Contrasted with County Meeting on Reservoirs
The public hearing last night before the Georgia Water Council on the University of Georgia campus contrasted in a number of ways with the public meeting a week earlier in Oconee County on proposed water reservoir options.
Georgia is running out of water and will not be able to provide enough water to meet the needs of state’s population in the next 25 years, Dr. Carol Couch, director of the Georgia Environmental Protection Division, said last night. As a result, preservation and conservation are essential.
A week earlier, Oconee County officials and their consultants said the County, based on high-end projections of population growth, needs a lot more water to feed planned and hoped for development in the County. As a result, the County needs to act quickly before others get the water first.
The Water Council meeting at the Georgia Center focused on the limited supply of water and what the state needs to do to protect it. The Oconee County meeting at the courthouse in Watkinsville focused on the limits state and federal regulations place on where the County can find water to put into its reservoir.
The Water Council meeting was intended to give residents a chance to comment on a Statewide Comprehensive Water Plan.
The Oconee County meeting on January 17th was to give citizens a chance to ask questions about two large reservoir projects that will draw water from the Oconee watershed. The County did not discuss plans to conserve that water, discourage its use, or guarantee that an adequate supply is put back into the rivers for downstream use.
The Georgia Water Council meeting was to obtain comments on the fourth objectives of the statewide master plan: protecting water quality. The other three are minimizing water withdrawal through conservation, reuse and efficiency, maximizing return of water to basins from which it was drawn, and meeting water demands.
One of the proposal of particular importance to those of us concerned about protection of the streams of the County is a call for increased resources for the EPD for stream monitoring.
April Ingle, executive director of the Georgia River Network, who has worked with us in our efforts to protect Barber Creek, spoke in favor in this proposal. I followed her comments and indicated how important monitoring is for Barber Creek.
I told the Council–and reminded Dr. Couch–that we have asked the EPD to modify the permit it has drafted for Oconee County’s proposed expansion of the Rocky Branch sewage plant. That permit would allow the County to discharge 1 million gallons per of plant effluent into Barber Creek.
At the December 12 hearing on the permit and subsequently, we submitted a petition signed by at least 45 residents asking the EPD to guarantee it will conduct independent sampling of Barber Creek on an unannounced basis at least once every three months during each year if it grants the permit.
I also reminded Dr. Couch that we asked that the permit be changed to allow Oconee County to discharge into Barber Creek only when the creek is at normal stage and to require the County to treat the water to drinking level quality.
The EPD should announce its decision on the draft permit at any time.
About 110 people attended the meeting last night at the Georgia Center. Many of them were government officials. Included were Oconee County Board of Commissioners Chairman Melvin Davis and Chris Thomas, assistant Oconee County Utility Department director.
April and I were among the 13 who spoke.
The first was Les Reed of Save Lake Oconee’s Waters. He would not have been happy had he attended the meeting on the 17th in Oconee County.
Reed said Lake Oconee and the Oconee River already are getting an inadequate supply of water and asked that no more water be taken from the River.
Both of the reservoirs Oconee County is considering building would do just that. One would draw water from the Oconee directly; the other would take water from the Apalachee, which flows into the Oconee.
Monday, January 22, 2007
Citizens Pose Lots of Questions at Hearing
About 60 people attended the meeting last night to learn more about the County’s plans for water treatment. The County did a nice job of allowing questions, and there were many. The meeting lasted about two hours.
What is clear is that the County at present plans to pick between two expensive, large projects, one in Walton County and the other in Oconee. Other options were acknowledged but dismissed as not suitable by the two consultants who spoke, William Martello of Jordan Jones & Goulding and Jimmy Parker of Precision Planning.
This is not much of a surprise. Martello developed the Oconee project; Parker is involved with the Walton project.
Costs are more than $100 million in both cases.
County Commission Chairman Melvin Davis said the County is going to decide in the next month or two what it wants to do.
Davis, Martello and Parker argued that the County is going to run out of water soon. The data to support that were sketchy. At one point, Wayne Provost, the director of strategic and long-range planning for the County, said the County had never linked those projections to land use plans. He acknowledged that the current plans do not even call for water services to be provided throughout the County.
Martello said he was using the high projections for population growth and acknowledged that the County has not been growing at the rate to match these projections. He said he did not want to be conservative.
Several of us asked why the County has not considered integrating its sewage treatment and water treatment plants, since they use the same basic technology to treat water and the County has been arguing that the product of its existing and proposed sewage plants is "near drinking level quality."
We had to ask the question several times. Finally, the answer was that the County officials and consultants do not believe the people of this County are smart enough to understand that one way or the other we are reusing water and will be doing so in the future.
Residents of the County will be willing to drink the treated sewage water from other counties (such as Clarke County, which is upstream of the planned Barnett Shoals reservoir), but they will not be willing to drink their own treated sewage water, we were told.
The irony is that, if either of these reservoirs is built, and if the County expands the Rocky Branch sewage treatment plant as it proposes, dumping treated sewage water into both Barber Creek and the Apalachee, we would be drinking our own sewage water regardless of which of the two proposed reservoirs we would draw from.
Perhaps the biggest unanswered–but repeatedly asked–question of the night was: How is the County going to pay for either of these reservoirs.
The answer, we were told, has not yet been developed.
Sunday, January 14, 2007
Important to Attend Two Upcoming Meetings
Two important meetings are taking place this week and next, both on Wednesday evenings.
At 7 p.m. on January 17, the Oconee County Board of Commissioners (BOC) will hold a hearing on plans for a water reservoir at the courthouse in Watkinsville.
From 5:30 to 8 p.m. on January 24, The Georgia Water Council will discuss statewide water management in Masters Hall at the Georgia Center for Continuing Education, 1197 S. Lumpkin St., on the UGA campus.
Stories about the January 17 meetings have appeared in all three papers. All indicate the County is seeking citizen input on two reservoir options. The County could go forward with its previously announced plans to build a reservoir on Barnett Shoals road, or it could join Walton County in construction of a reservoir on Hard Labor Creek. The County pulled out of the Walton County project last year in favor of the Barnett Shoals project.
Likely County Already Decided
The stories have said this is an opportunity for citizens to express their views of the options, but it seems clear the County has already made its choice. The January 11 edition of the Oconee Enterprise contains a legal notice of the hearing, which would not be required if this were merely a discussion of options.
The story in the January 11 issue of The Oconee Leader, which quotes BOC Chairman Melvin Davis extensively, suggests this is a public hearing on the County’s decision to rejoin Walton County.
Both options involve more than $100 million in County expenditures. Apparently not up for discussion is not going forward with either of these projects.
According to the story in the Leader, the County used 2.6 million gallons per day of water in 2005. At one place in the article, Chairman Davis is quoted as saying the County might need 12 million gallons per day in 2050. He also is quoted as saying the County "probably will need more water in 2013 or 2014" than it can get from the Bear Creek reservoir in Jackson County.
The Bear Creek reservoir first started supplying water in 2002 to Barrow, Clarke, Jackson and Oconee counties. According to the web site of the engineering company Golder, which provided construction monitoring for the reservoir, the 505-acre reservoir and treatment plant have a capacity of 45 million gallons of water per day.
Water "Needed" to Encourage Growth
Chairman Davis said the County "needs" more water for growth. That, of course, is what the decision on January 17 will focus on: how to develop a water source to encourage more growth in the County.
More water coming into the County means more water flowing to its two sewage treatment plants, including the plant on Rocky Branch road. The County is seeking a permit at present to discharge 1 million gallons per day of water from that plant into Barber Creek. The County is considering expanding that plant to 4 million gallons per day of discharge in the future.
To build the Barnett Shoals reservoir, the County would need a permit to draw water out of the Oconee River. The Hard Labor Creek reservoir would draw water from the Apalachee River. The Bear Creek Reservoir currently takes its water from the Middle Oconee.
The Georgia Water Council meeting on January 24 at the Georgia Center is part of an effort to create a statewide Water Management Plan. The Water Council is a coordinating committee created by the Georgia 2004 Comprehensive Statewide Water Management Planning Act, which mandates the development of a statewide plan.
EPD Has Four Objectives
The Georgia Environmental Protection Division (EPD), with the oversight of the Water Council, has developed four major water management objectives: (1) Minimize withdrawals of water by increasing conservation, reuse, and efficiency, (2) Maximize the return of water to river basins, (3) meeting water demands through efficient surface water storage and aquifer management, and (4) protecting water quality by reducing discharges of pollutants to streams and runoff from land.
At the meeting, the Water Council will present draft policy recommendations on water quality and take comments on policy options to be addressed by the Comprehensive Statewide Water Management Plan.
The first half hour of the meeting will give participants an opportunity to view displays and materials related to the water planning process.
Some of the Water Council objectives seem at odds with those of Oconee County.
Oconee County is trying to develop a demand for treated water from its Rocky Branch sewage plant for use in lawn irrigation. When there is no demand because of heavy rains, the treated sewage water will go into Barber Creek, where it ultimately will flow to the Middle Oconee and Oconee. When these streams might benefit from increased volume, in other words, they will not get it.
Integration of Water and Sewage Treatment
An option the County has not discussed is integrating its sewage treatment and water treatment facilities to make maximum use of the limited water resource.
That would require the County to treat its sewage water to drinking level quality. It can be done, but it will not be done if the County is allowed to discharge lesser quality water into Barber Creek and allowed to encourage, rather than discourage, the use of water for lawn irrigation.
Please try to attend both of these meetings and to raise questions at both about how we can use and protect all our streams, not just Barber Creek.
Friday, December 29, 2006
Details of Friends' Challenge to EPD Draft Permit
The Board of Directors of the Friends of Barber Creek, in documents submitted at the December 12 hearing before the Environment Protection Division and afterwards, has asked the EPD to deny Oconee County’s request for a permit to discharge wastewater into Barber Creek from an expanded Rocky Branch waste treatment facility.
The board made the request because it believes the County and the EPD incorrectly identified the receiving stream for the effluent, because it believes the County did not correctly post public notice about a hearing it held on the permit application in March of 2006, and because it believes Barber Creek already violates one state standard for water quality.
All three of these issues were raised by speakers at the public hearing at the Oconee County Civic Center on December 12. Reporters for the Athens Banner-Herald and The Oconee Enterprise did not include them in their stories on the meeting. The Oconee Leader did.
I gave reporters for all three papers copies of documents that support the Board’s position on the issued raised. (These documents are available on the Friends of Barber Creek web site, www.barbercreek.org.)
Included in the documents I gave the reporters were copies of an e-mail exchange between me and Chris Thomas, assistant director of the Oconee County Utility Department, stating that the County planned to discharge wastewater from the Rocky Branch plant into an unnamed tributary of Barber Creek, although the County had sought permission from the state to discharge directly into Barber Creek.
I also gave the reporters copies of the notices published by law in The Enterprise for the March 14 hearing. Neither of the notices published named the receiving waters for the discharge.
Allan Antley, the first of the speakers at the December 12 hearing, told the EPD that, based on data provided by the County, Barber Creek already exceeds the allowable level of fecal coliform bacteria and asked the EPD to deny the permit on that basis.
The e-mail exchange with Chris Thomas is unambiguous. It also was copied to Gary Dodd, director of the Utility Department. Here is what I asked Mr. Thomas on Tuesday, 9/5/2006:
"(F)rom the map (on the draft permit written by the EPD) and from other maps I have viewed, it appears to me that the discharge from the plant will not be directly to Barber Creek but rather to the unnamed tributary of Barber Creek on the northwest side of the property. Is this correct? Is this a flowing stream, or is it normally dry?"
Here is what Mr. Thomas said on Wednesday, 9/6/2006:
"The discharge will be into the feeder creek. The creek flows year round and actually has a very good existing flow."
The two public notices in The Enterprise also are clear, and, according to the County, these are the only two such notices that were published. One appeared on February 9, 2006, and the other on February 23, 2006. Neither of them makes any reference to Barber Creek or any stream.
The public simply was simply to provide input on the proposed upgrade to the Rock Branch Land Application System. The upgrade, according to the ads, "will allow for treatment of 1.0 million gallons per day (MGD) of wastewater to reuse quality standards." What will be done with the wastewater is not specified.
The fecal coliform standard is more complicated. On page 2 of the Fact Sheet attached to the draft permit handed out at the meeting, Water Quality Standards are listed. For the Months of May through October, fecal coliform is not to exceed an average of 200 fecal coliform units per 100 ml of water. For the months of November through April, fecal coliform cannot exceed 1,000 fecal coliform units per 100 ml.
The standard allows for some deviations for the 200 fecal coliform unit limit during the summer, "when contact recreation activities are expected to occur," but the standard says the deviation would have to be from non-human sources.
At the December 12 meeting, Oconee County officials presented a chart at the rear of the room showing that its samples from Barber Creek showed an average fecal coliform units of 219. No detail on the sampling dates or procedures was provided.
The County also presented this chart at the March 14 hearing. At that meeting, according to the official transcript, Mr. Thomas said some fecal coliform readings from Barber Creek have been as high as 512. The source for the data in the chart was the Watershed Protection Plan–Barber Creek and Calls Creek Watersheds, September 2005. The document was prepared by consulting firm Jordan Jones and Goulding (JJG).
Getting access to County data on the quality of water in Barber Creek has not been easy. On August of this year, I asked Mr. Thomas for data on Barber Creek in an email message. He responded the next day saying the County did not have sampling data from Barber Creek.
I filed an open records request with the County on December 19, 2006, asking for access to The Watershed Protection Plan–Barber Creek and Calls Creek Watersheds, prepared in September of 2005 for the County by JJG and for "any other documents or reports in possession of the County or its consultants containing information about the quality of water in Barber Creek or Calls Creek that have been produced since 2000."
On December 28, 2006, I reviewed the 2005 Watershed Protection Plan of JJG as well as a second report, also produced by JJG, called Final Report, February 2004, Watershed Assessment and Protection Plan Calls Creek and Barber Creek Watersheds.
Both documents contain tabled data showing fecal coliform counts for three sites on Barber Creek, all in Oconee County. According to both tables, the data come from May to November of 2000. The tables do not agree, however, and the 219 figure appears only in the 2005 report. The 219 figure is labeled as for the May to November period for one of the sites, with a reading of 572 for the "dry" months and 101 for the "wet" months. Another of the sites produced a reading of 337 for the May to November period.
The tables also contain data for Calls Creek, where the County currently operates a treatment plant. One of the readings for Calls Creek was 1,020!
In our filing with the EPD after the hearing, we also indicated that data gathered on May 1, 2002, by The Watershed Group at the University of Georgia as part of a City of Statham watershed assessment show three samples drawn from three different sites on Barber Creek in Barrow County with fecal coliform readings in excess of 500. Two of those samples were in excess of 1000.
We also argued that EPD has erred in not examining the condition of Barber Creek and the unnamed tributary to Barber Creek before issuing a Waste Load Allocation. Since Oconee County officials repeatedly have asserted that Barber Creek already is polluted, we wrote, it was inappropriate for the EPD to issue a Waste Load Allocation based solely on inferences about the quality of the water in the Creek from a theoretical model.
The Waste Load Allocation is the EPD's determination that a stream is capable of receiving polluted water.
In addition, we said, we fell the EPD has erred in not incorporating into the assessment of the application the adverse effects of the increase in volume of water in Barber Creek because of the Rocky Branch waste treatment plant. Barber Creek frequently floods, we noted, and any increase in water at flood stage will adversely affect the property of citizens downstream from the plant and increase the possibility of loss of life and injury.
Why the Banner-Herald and Enterprise stories ignored the specifics of the Friends of Barber Creek challenge to the County is an interesting question. The Oconee Leader has consistently provided the best coverage of this topic, though it, too, ignored the fecal coliform part of the challenge.
What we are saying is pretty simple. We think the County should have to tell people where the sewage water is going to be discharged in the public notice for a hearing on the topic. We think the application should correctly identify the stream, and we think the permit should as well. And we do not think a permit should be issued if Barber Creek already violates the state standard for water quality. We think water volume should be considered in making a decision.
The EPD will have to respond to the Friends filing, probably in January or February.
In the meantime, please refer anyone interested in the issues we raised to this posting and the Friends web site. It is pretty clear that we cannot depend on at least two of the newspapers to tell the story.
Sunday, December 10, 2006
To Fix Barber Creek, Add Some Treated Sewage Water
Barber Creek is so dirty that even treated sewage water cannot hurt it, Oconee County officials have been saying for the last two years.
In fact, according to those officials, a little treated sewage water would do the Creek some good.
The story, as it turns out, is more complicated than that.
Little is known about the quality of water in Barber Creek, largely because the Georgia Environmental Protection Division does not take into consideration the actual quality of the water in a stream in making its decision about the ability of the stream to handle sewage plant discharge!
In fact, the state of Georgia has not studied Barber Creek and has only general notions about how clean or dirty Barber Creek is where Oconee County plans to discharge 1.0 million gallons per day of sewage water from its Rocky Branch plant.
The state made its decision about waste load allocations–the preliminary and controlling decision in drafting a permit to discharge into Barber Creek–without even gathering data on the quality of water in the stream or requiring Oconee County to submit data of that sort.
The EPD used maps and descriptive data on the Creek’s size and volume of flow to estimate, based on theoretical models, how much dirty water the Creek can handle.
Then the EPD told Oconee County that Barber Creek could handle more pollutants–based on those theoretical models, not on a knowledge of how dirty or clean the Creek actually was.
The EPD informed Oconee County it had to design a plant that would produce discharge that would not exceed set standards for 10 characteristics: flow, biochemical oxygen demand, ammonia, dissolved oxygen, total suspended solids, total residual chlorine, fecal coliform bacteria, pH, total phosphorus, and turbidity.
Oconee County has designed its planned expanded sewage treatment plant on Rocky Branch road with these requirements in mind, and the EPD has issued a draft permit for the County.
Citizens will get a chance to ask questions about that draft permit in a meeting scheduled by the EPD for 7 p.m. on Tuesday, December 12, 2006, at the Oconee County Civic Center on Hog Mountain road.
Citizens can ask what the state really knows about the quality of water in Barber Creek and why it believes it can handle reuse quality water–also called grey water–from a sewage plant.
Citizens also can ask the state to begin taking action to actually clean up the Creek if the Creek is as dirty as Oconee County officials say it is.
Paul Lamarre, an expert on the modeling the EPD uses to make the decisions about sewage plant discharges, was kind enough to explain the process to me in detail in two different telephone conversations I had with him the week of November 27, 2006. He also referred me to documents on the models used to make the allocation.
The modeling process, he emphasized, involved "no raw data" based on samples of water taken from Barber Creek.
Mr. Lamarre said he expects to attend the hearing the EPD has scheduled for December 12.
Even if Barber Creek is as dirty as County officials claim, part of the logic of the argument that a little more dirty water will do it some good is wrong, according to the information Mr. Lamarre gave to me.
A big focus in the waste load allocation decision, he said, is the theoretical amount of dissolved oxygen in a stream. Dissolved oxygen, up to a point, is good, since the bacteria in a stream that break down biodegradable materials that enter the stream require oxygen to do their work.
Water coming out of a sewage plant usually is high in dissolved oxygen, since part of the treatment process involves stirring the water. Oxygen is dissolved in the water through contact with the air.
The amount of oxygen in a stream also is affected by temperature, and a slow-moving stream low in volume in warm weather would benefit from the addition of water high in oxygen. But a colder stream, which holds more oxygen naturally, with a higher volume isn’t as likely to gain as much from the addition of water high in dissolved oxygen.
Yet Oconee County officials have been clear in saying they plan to discharge into Barber Creek from the Rocky Branch plant when they cannot sell the reuse water for irrigation. They won’t put the water in the Creek when it might do some good, in other words, but only when the Creek isn’t like to benefit much from the additional dissolved oxygen.
The other contaminants that are in sewage water–such as fecal coliform and ammonia–will only add to the amount of contaminants in the stream. Because of the increased volume, these contaminants will be diluted.
The County actually began the process that will come to a head with a decision on a discharge permit in September of 2004 when it asked the EPD for a Waste Load Allocation for Barber Creek. It was granted the allocation in August of 2005. Since that time, it has gone forward with the permitting process, filling out forms and submitting information about the plant.
The County, however, has not provided the state with data on the quality of water in Barber Creek in applying for the Waste Load Allocation or in any of the documents released to the public prior to a March 14 hearing.
The assertion that Barber Creek is currently so dirty comes from sampling data included in separate report produced by consulting firm Jordan Jones and Goulding in September of 2005.
At the hearing the County held on March 14, 2006, officials made reference to the data from those samplings and the characteristics of effluent from the County’s only other sewage treatment plant, now operating on Calls Creek. The Rocky Branch plant will be similar to the Calls Creek plant in design.
The charts showed that Total Suspended Solids and Fecal Coliform levels were higher in Barber Creek than in the effluent from the Calls Creek plant.
Chris Thomas, assistant director of the Oconee County Utility Department, acknowledged that there is a lot of variation in samplings from Barber Creek. "It’s your discretion as to whether your children play in the Creek," he said. "I was born and raised in Oconee County. I played in creeks my whole life. Getting in them now, I kind of think twice about it because I see samples like that."
Wayne Provost, long-time County official and planner, told those at the hearing that the new treatment plant would allow the County to put water back into Barber Creek that "would be a better quality of water than what’s in Barber Creek upstream from the facility."
Jimmy Parker, senior project manager at Precision Planning Inc., another consulting firm aiding the County, pointed to a jar of water from Barber Creek and a jar of water from the treatment plant. "I mean, it’s crystal clear," he said of the latter.
Even if it is true that Barber Creek is now polluted–and it would be a surprise if it were not given that it now flows through so much urban sprawl in the County--the addition of "crystal clear" water won’t help the kids playing in the Creek unless the County changes its plans.
Kids don’t play in the Creek when the water is cold, but that is when the County plans to discharge its treated effluent.
When the Creek is low and hot and flowing slowly, the "crystal clear" water is going to be used on spray fields and for irrigation of lawns and recreation facilities.
It is just another part of the confusing story surrounding the County’s plans for sewage treatment and discharge into Barber Creek.